CAT/C/68/D/863/2018 statements she had made in 2009 about her experiences in Côte d’Ivoire, that there were no medical reports to corroborate her claim that inconsistencies in her accounts resulted from physical or mental health problems, and that her allegations that she had been imprisoned, tortured and raped were not credible. 2.16 On 14 April 2014, the complainant applied to the District Court of The Hague for judicial review of the decision of the Immigration and Naturalization Service. The Institute for Human Rights and Medical Assessment conducted a medical examination of the complainant and presented its report to the District Court. In the report, the Institute stated that the complainant’s psychological condition was typical for the type of trauma she had endured, and that her injuries were consistent with the nature of the harm inflicted. The Institute also stated that the complainant could not be expected to provide a full and consistent account of every detail of her experiences. 2.17 On 8 January 2016, the District Court declared the complainant’s application for judicial review well-founded. In its decision, it referred to the findings of the Institute for Human Rights and Medical Assessment, according to which the complainant’s psychological symptoms were typical for the type of trauma she had experienced. The District Court considered that the report of the Institute represented an expert opinion on the matter. The District Court considered that the Immigration and Naturalization Service had not given enough weight to the complainant’s medical situation and its effect on her statements. 2.18 On 12 February 2016, the Minister for Migration appealed against the decision of the District Court before the Administrative Jurisdiction Division of the Council of State. On 21 September 2016, the Division granted the Minister’s appeal, considering that the complainant’s story lacked “positive persuasion”, since it was inconsistent with respect to the core of her narrative and certain details. The Division reversed the decision of the District Court, and declared the complainant’s application for judicial review unfounded. 2.19 In separate, parallel proceedings, on 23 October 2014, the complainant applied to the Immigration and Naturalization Service for prolongation of her residence permit, arguing that she had demonstrated compelling reasons to be permitted to remain in the Netherlands, because she was too damaged to return to the country where she had been abused and tortured for a prolonged period. Under domestic law, residence permits may be granted for compelling reasons. However, on 21 October 2016, the Service denied the complainant’s application, on the ground that she did not meet the legal requirements for renewal of her residence permit. On 16 June 2017, the District Court of the Hague rejected the complainant’s application for judicial review of the decision of the Service. The District Court considered that during proceedings before lower instances, the complainant should have presented her argument that the denial of social benefits constituted cruel and inhumane treatment. On 6 July 2017, the complainant filed an appeal against the decision of the District Court before the Administrative Jurisdiction Division. On 21 July 2017, the Division rejected the appeal without stating the basis for its decision. 2.20 The complainant states that she has exhausted all domestic remedies and has not submitted the same matter to another international body for examination. The complaint 3.1 The complainant asserts that the State party would violate her rights under article 3 of the Convention by removing her to Côte d’Ivoire, where she suffered severe trauma, torture and cruel and inhuman treatment. State agents arbitrarily arrested the complainant, applied excessive force when transporting her to prison, arbitrarily imprisoned her, forced her to endure inhuman conditions of detention for four years, and repeatedly raped her in prison. The complainant is traumatized by the mere idea of returning to her country of origin. 3.2 In addition, the complainant fears that she will be raped again if she is returned to Côte d’Ivoire. She might run into the individuals who assaulted her, and while such an encounter might not be foreseeable, her fear of having to confront them is overwhelming. The complainant might also encounter places, situations and smells that will retraumatize her. 4